American Axle & Manufacturing Holdings Inc

American Axle & Manufacturing Holdings Inc has integrated its lobbying governance into its sustainability framework and requires that "activities that further the Company's overall climate change strategy are subject to approval of the corporate Policy Committee and/or the CEO," with the President (the Sustainability Program Lead) tasked to present high-level decisions and report approvals to the Board of Directors. The company affirms that this oversight applies to "direct and indirect activities that may influence policy," noting that "as a member of these trade associations, our participation is indirect." While this demonstrates clear oversight structures and defined processes, we found no evidence of a dedicated procedure to evaluate or adjust the climate positions of its trade associations or to exit or correct misaligned bodies, and the company explicitly states, "No, and we do not plan to have one in the next two years," regarding a Paris Agreement-aligned engagement statement. Moreover, the fact that there were "no activities requiring such approval during 2021" suggests limited operational application of this framework to date.